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TMI Blog2017 (6) TMI 1274X X X X Extracts X X X X X X X X Extracts X X X X ..... ee. It is providing round the clock service to the clients from various aspects from letting out of goods, their security etc. will definitely fall within the purview of business income. We also find from the order of the id. CIT(A) that the A.O. has accepted the claim of the assessee and treated the income as business income in assessment years 2005-06 & 2006-07. - decided in favour of assessee. - ITA No. 206/Mum/2015 - - - Dated:- 22-6-2017 - Sh G.S. Pannu And Sh. Pawan Singh, JJ. Revenue by. Shri Dr . A.K. Nayak, DR Assessee by. Miss Arat i Vissanj i, AR ORDER Pawan Singh, This appeal by Revenue under section 253 of Income Tax Act is directed against the order of Commissioner of Income Tax (Appeals)-29 [CI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Tribunal passed the following order in Para 4 which reads as under: - 4. After considering the facts on record and the rival contentions put forward before us, we observe that the assessee is not merely letting out its premises for warehousing but were doing complex commercial activity. All the duties cast upon the assessee was responsible for ensuring the incoming and, outgoing of goods apart from providing adequate security. The consideration received by the assessee from client is not for letting the property on rental basis but the consideration received is exclusively for providing the benefits of business service facilities to the client. The assessee is not providing warehousing sex-vice to one or two fixed customers. There i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rder, we do not find anywhere in accepting any additional evidences. The Ld. D.R. also failed to show us any additional evidences which were the ld. CIT(A). Thus, when it is a fact on record that the Id. CIT(A) has not accepted any additional evidence, is no question of violation of Rule 46-A by the ld. CIT(A). Therefore, this ground of the Revenue is also dismissed Considering the above refer decision of the Tribunal, we find that the grounds of appeal raised by Revenue are squarely covered against the Revenue. The facts of the present and grounds of appeal raised by Revenue are exactly identical. By considering the above appeal in assessee s own case, we do not find any merit in the appeal raised by the Revenue. Hence, we dismiss the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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